Contributing Firms:
The Irish Tax Monitor February 2024
In this issue

The Global minimum tax enables better than ever ‘best-in-class’ tax structures

2024 brings with it ‘a brand new tax system’ as BEPS Pillar Two, which includes the introduction of a minimum tax rate for the world’s largest corporates, enables a once-in-a-generation reform of Ireland’s corporate tax regime. These BEPS reforms and further planned moves at EU level, such as ‘Unshell’ proposals, mean refinements to Ireland’s tax offering will be required to remain competitive.


2023’s tax highlights; participation exemption; share-based remuneration

In this month’s roundtable the Department of Finance’s plans to introduce a participation exemption for corporation tax features with the move welcomed as ‘extremely positive’ despite the proposed implementation date being later than hoped for. The tax highlights and lowlights for 2023 also feature with the aforementioned participation exemption chosen in the former category, as does BEPS Pillar Two. The opportunities to improve Ireland’s personal taxation regime are also analysed as is the Department of Finance’s review of the taxation of share-based remuneration and the broader Irish share scheme environment, the new CESOP regime, effective 1st January 2023 and new Revenue guidance on VAT treatment of portfolio management services.


Participation Exemption

The Department of Finance’s consultation period on the introduction of a Participation Exemption for Corporation Tax ended in mid-December. Can you comment on the plans?


2023 highlights

What would you consider to have been the tax highlights of 2023?


2023: highlights and lowlights

What would you consider to have been the tax highlights of 2023 and what would you consider to have been the tax lowlights of 2023?


Share-based remuneration

The Department of Finance is to review the taxation of share-based remuneration and the Irish share scheme environment. The project is set to be undertaken over the coming months and will take on board feedback received from the recently launched Public Consultation on share-based remuneration. What changes do you suggest can be made to ensure Ireland’s offering around share-based remuneration can ‘support Irish companies in attracting and retaining highly skilled and motivated employees’ (as the Department of Finance’s review aims to do).


VAT

The Revenue Commissioners have recently updated guidance on the VAT treatment of portfolio management services. Can you outline the changes and any implications for taxpayers?

CESOP

What are the key elements of the new Central Electronic System of Payment Information (CESOP) regime?


Personal Taxation

In your experience as a tax practice, in which areas in Ireland’s personal income tax structures offer the greatest scope for success in pursuing the reforms recently recommended by the IMF in its annual Report on Ireland? (i.e. ‘improving personal income tax system’).


Tax Technology

Would you comment on significant developments, and the major trends to watch for in 2024 and beyond in the area of tax technology?


This Month's Roundtable

The Questions

Participation Exemption: The Department of Finance's consultation period on the introduction of a Participation Exemption for Corporation Tax ended in mid-December. Can you comment on the plans? (including any points your firm may have made in a submission as part of the consultation process).

Highlights of 2023: What would you consider to have been the tax highlights of 2023? (In your answer please refer to Irish, EU and global highlights.)

Lowlights of 2023: What would you consider to have been the tax lowlights of 2023? (In your answer please refer to Irish, EU and global highlights.)

Taxation and share based remuneration: The Department of Finance is to review the taxation of share-based remuneration and the Irish share scheme environment. The project is set to be undertaken over the coming months and will take on board feedback received from the recently launched Public Consultation on share-based remuneration. What changes do you suggest can be made to ensure Ireland's offering around share-based remuneration can 'support Irish companies in attracting and retaining highly skilled and motivated employees' (as the Department of Finance's review aims to do).

VAT and Portfolio Management Services: The Revenue Commissioners have recently updated guidance on the VAT treatment of portfolio management services. Can you outline the changes and any implications for taxpayers?

CESOP: What are the key elements of the new Central Electronic System of Payment Information (CESOP) regime?

Personal Taxation : In your experience as a tax practice, in which areas in Ireland's personal income tax structures offer the greatest scope for success in pursuing the reforms recently recommended by the IMF in its annual Report on Ireland? (i.e. 'expanding and diversifying tax revenues including by improving personal income tax system'). The IMF report is available here.

Tax Technology: Would you comment on significant developments in the area of tax tech in 2023, and the major trends to watch for in 2024 and beyond?